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510(k) Data Aggregation

    K Number
    K233924
    Manufacturer
    Date Cleared
    2024-04-18

    (127 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    EMBOGUARD Balloon Guide Catheters are indicated for use in facilitating the insertion and guidance of an intravascular catheter into a selected blood vessel in the neurovascular system. The balloon provides temporary vascular occlusion during angiographic procedures. The Balloon Guide Catheter is also indicated for use as a conduit for Retrieval Devices.

    Device Description

    EMBOGUARD Balloon Guide Catheter is a dual lumen, braid-reinforced, variable stiffness catheter with an eccentric inflation lumen, a radiopaque marker on the distal end and a bifurcated luer hub on the proximal end. A compliant balloon is mounted on the distal end. The distal end of the device shaft has a hydrophilic coating. Balloon Guide Catheter dimensions are indicated on the product label.

    AI/ML Overview

    The provided text is an FDA 510(k) summary for a medical device called the EMBOGUARD™ Balloon Guide Catheter (K233924). This document primarily focuses on establishing "substantial equivalence" of the new device to a previously cleared predicate device (K212340), rather than proving the device meets acceptance criteria through a traditional clinical study with defined performance metrics for AI/software.

    The context of your request seems to imply the device might be an AI or software-based product given your detailed prompts about MRMC studies, ground truth, and expert adjudication. However, this FDA submission is for a physical medical device (catheter) and not an AI or software device. Therefore, many of the specific questions you've asked (e.g., sample size for test/training sets for AI, number of experts for ground truth, MRMC study, standalone algorithm performance) are not applicable to this type of device submission.

    The "acceptance criteria" discussed in this document relate to bench testing, biocompatibility, and sterilization to demonstrate that the modified physical device performs as safely and effectively as its predicate.

    Based on the provided text, here's what information is available and how it aligns (or doesn't align) with your request:


    Device Type: Physical Medical Device (Balloon Guide Catheter), not an AI/software device.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document describes several performance tests with "Pass" results, indicating adherence to pre-determined acceptance criteria. However, quantitative acceptance criteria are generally not explicitly stated with specific numerical values in this summary, but rather implied by meeting internal specifications or relevant standards.

    Here's a summary of the performance categories and their reported outcomes:

    Performance Test CategoryAcceptance Criteria (Implicit)Reported Device Performance
    BiocompatibilityDevice should be non-cytotoxic, non-sensitizing, non-irritating, non-systemically toxic, non-pyrogenic, non-hemolytic, not activate complement, and demonstrate similar thromboresistance to control. (Per ISO 10993 series & ASTM F756-17)Pass: All tests met pre-determined acceptance criteria. Non-cytotoxic, did not elicit sensitization, met intracutaneous reactivity, met systemic toxicity, non-pyrogenic, non-hemolytic, does not activate complement, demonstrates similar thromboresistance to control.
    SterilizationAchieve minimum sterility assurance level (SAL) of 10-6. Remain sterile for 1 year shelf life.Pass: Sterilization process successfully validated to 10-6 SAL. Device and packaging remain functional and sterile for 1 year shelf life.
    Bench TestingMeet specifications for inflation/deflation time, fatigue, OD/compliance, concentricity, burst pressure, sheath compatibility, lumen integrity, deliverability, flexibility/kink resistance, torque durability, tensile strength, visual, particulates, tip stiffness.Pass: All samples met pre-determined acceptance criteria for all listed tests (Inflation/Deflation Time, Balloon Fatigue, OD & Compliance, Concentricity, Burst, Sheath Compatibility (Insertion/Withdrawal & Re-insertion/Re-withdrawal), Inner Lumen Integrity (Pressure & Aspiration), Deliverability & Withdrawal Force, Flexibility & Kink Resistance, Kink to Failure (Characterization), Torque Durability, Torque to Failure, Visual Inspection, Particulates (Comparable to Predicate), Tensile Strength, Tip Stiffness (Comparable to Predicate)).

    Note on Quantitative Data: For most bench tests, the summary states "All samples met the pre-determined acceptance criteria." without providing the specific numerical criteria or the actual measured values. For "Kink to Failure" and "Particulates", it's noted as "Characterization only" or "found comparable," indicating that precise numerical "pass/fail" limits might not have been applied as rigorously as for other tests, but rather assessed for equivalence to the predicate.

    2. Sample Size for the Test Set and Data Provenance

    • Sample Size for Test Set: Not explicitly stated in the summary for each individual test. The document mentions "All samples" for the bench tests, implying a sufficient number were tested per internal protocols and relevant standards. For biocompatibility, it refers to standard test methods where sample sizes are typically defined by those standards.
    • Data Provenance: Not applicable in the context of patient data. The "data" here comes from laboratory bench testing and biological assays conducted according to established protocols and standards. The testing was conducted by or for Neuravi Ltd., based in Ireland.

    3. Number of Experts and Qualifications for Ground Truth

    • Not Applicable: This is a physical device, not an AI/software system requiring expert interpretation of medical images. Ground truth for its performance is established through physical measurements, chemical assays, and mechanical tests according to engineering and biocompatibility standards.

    4. Adjudication Method for the Test Set

    • Not Applicable: There is no "adjudication" in the sense of multiple human readers independently evaluating data for consensus, as would be done for an AI/software device. Performance is determined by objective measurements against predefined engineering specifications and biological safety limits.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done

    • No: This type of study is relevant for AI/software devices that assist human interpretation of medical data. It is not applicable to a physical catheter.

    6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done

    • Not Applicable: As stated, this is a physical medical device, not an algorithm.

    7. The type of ground truth used

    • Physical/Chemical Standards and Measurements: For biocompatibility, ground truth is based on established biological responses (e.g., cell viability for cytotoxicity, skin reaction for irritation, blood parameters for hemolysis) as defined by ISO 10993 series standards. For bench testing, ground truth is based on engineering specifications and mechanical properties (e.g., measured burst pressure, inflation time, pull strength, visual inspection against defects).

    8. The sample size for the training set

    • Not Applicable: This is not an AI/software device that requires a training set. The device itself is manufactured, not "trained."

    9. How the ground truth for the training set was established

    • Not Applicable: No training set or ground truth in the context of machine learning. The "ground truth" for the device's design and manufacturing is based on established engineering principles, material science, and regulatory standards for medical devices.
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    K Number
    K212340
    Manufacturer
    Date Cleared
    2021-12-17

    (142 days)

    Product Code
    Regulation Number
    870.1250
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    EMBOGUARD Balloon Guide Catheters are indicated for use in facilitating the insertion and guidance of an intravasular catheter into a selected blood vessel in the neurovascular system. The balloon provides temporary vascular occlusion during angiographic procedures. The Balloon Guide Catheter is also indicated for use as a conduit for Retrieval Devices.

    Device Description

    EMBOGUARD Balloon Guide Catheter is a dual lumen, braid-reinforced, variable stiffness catheter with an eccentric inflation lumen, a radiopaque marker on the distal end and a bifurcated luer hub on the proximal end. A compliant balloon is mounted on the distal end. The distal end of the device shaft has a hydrophilic coating. Balloon Guide Catheter dimensions are indicated on the product label.

    AI/ML Overview

    This document describes the regulatory submission for the EMBOGUARD™ Balloon Guide Catheter (K212340). As such, the "acceptance criteria" and "device performance" refer to the results of bench and animal testing demonstrating substantial equivalence to a predicate device, rather than performance metrics for an AI algorithm. Therefore, many of the requested fields are not applicable in this context.

    Here's a breakdown of the provided information, addressing your points where relevant:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission details numerous performance tests to demonstrate substantial equivalence to a predicate device. The general acceptance criterion for all of these tests is "Pass," meaning the device met the pre-determined specifications or demonstrated comparable performance to the predicate. The reported device performance for all listed tests is "Pass," indicating that all samples met the pre-determined acceptance criteria.

    Study NameAcceptance CriteriaReported Device Performance (all samples)
    Visual Inspection and Dimensional VerificationMet visual & dimensional specificationsPass
    Visual Surface InspectionMet visual surface requirementsPass
    Torque DurabilityCapable of 360 degrees hub rotationPass
    Torque to FailureMet pre-determined acceptance criteriaPass (characterized only)
    Torque TransmissionTorque transmission characterizedPass (characterized successfully after min 720° hub rotation)
    Tensile StrengthMet tensile strength requirementsPass
    Flexibility and Kink ResistanceAcceptable flexibility & kink resistancePass
    Kink to FailureDetermined bend radius at which kink occursPass (characterized at different sections down to 2.5mm mandrel)
    Catheter Lubricity and DurabilityMet coating lubricity & durability specificationsPass
    Coating Length and LocationMet coating length & location specificationsPass
    ParticulatesParticulates comparable to cleared controlsPass (characterized only)
    Coating IntegrityCoating characterized pre- & post-simulated usePass (characterized only)
    RadiopacityMet radiopaque characteristics requirementsPass
    Simulated UseDemonstrated device performance in simulated anatomyPass
    Simulated Clot Retrieval TestingDemonstrated device performance (incl. clot retrieval)Pass
    User EvaluationDemonstrated device performance in simulated anatomyPass
    Catheter Deliverability and Withdrawal ForceMet required tracking force specificationPass
    Catheter Luer Hub Dimensional and Performance TestingMet requirements for small bore connectorsPass
    Inner Lumen Integrity - PressureMet pressure requirementsPass
    Inner Lumen Integrity - AspirationMet aspiration air leakage requirementsPass
    Hub Shaft Pressure IntegrityMet minimum inner diameter specificationPass
    Introducer Sheath Compatibility (Insertion and Withdrawal)Met required insertion & withdrawal forcePass
    Introducer Sheath Compatibility (Re-insertion and Re-withdrawal)Device integrity maintained post re-insertion & re-withdrawalPass
    Tip StiffnessSimilar to predicate devicePass
    Balloon LocationMet balloon location specificationPass
    Balloon Inflation / DeflationMet inflation & deflation time specificationsPass
    Balloon FatigueNo degradation after 20 inflation cyclesPass
    Balloon OD and ComplianceMet max recommended inflation volume vs. balloon diameter specificationsPass
    Balloon ConcentricityMet balloon diameter specifications on each sidePass
    Balloon BurstCapable of withstanding 2x and 2.5x recommended inflation volumePass
    Conditioning, Distribution, and Shelf Life Aging - DeviceMet all specifications at baseline & after 1-year agingPass
    Conditioning, Distribution, and Shelf Life Aging - PackagingMaintained packaging strength & integrityPass
    Visual Inspection Packaging and LabelingMet packaging & labeling visual & adherence requirementsPass
    System Visual Inspection (Dilator)Met visual & dimensional specificationsPass
    Effective Length, Outer Diameter, Inner Diameter, Taper Diameter (Dilator)Met visual & dimensional specificationsPass
    Tensile Strength (Dilator)Withstood peak tensile strengthPass
    Kink Resistance (Dilator)No kinks, defects, or damagePass
    Luer Dimensional (Dilator Hub)Met dimensional specificationsPass
    Fluid Leakage by Pressure Decay (Dilator Hub)No leakage under pressurePass
    Sub-atmospheric Pressure Air Leakage (Dilator Hub)No air leakagePass
    Stress Cracking (Dilator Hub)No cracking under axial force & torquePass
    Resistance to Separation from Axial Load (Dilator Hub)No separation from reference connectorPass
    Resistance to Separation from Unscrewing (Dilator Hub)No overriding of threadsPass
    Resistance to Overriding (Dilator Hub)No overriding of threadsPass
    Torque Durability (Dilator Hub)No separation/embolization after 1 rotationPass
    Visual Inspection (Luer Activated Valve)Met visual specificationsPass
    Leak Test (Luer Activated Valve)No leakage during inflation/deflationPass
    Activation (Luer Activated Valve)Allowed flow, no leakage when activated, prevented flow when syringe removedPass
    LAV Male & Female Luer Dimensional (Luer Activated Valve)Met dimensional specificationsPass
    Fluid Leakage by Pressure Decay, Sub-atmospheric Pressure Air Leakage (LAV)No leakage under pressurePass
    Stress Cracking (LAV)No cracking under axial force & torquePass
    Resistance to Separation from Axial Load (LAV)No separation from reference connectorPass
    Resistance to Separation from Unscrewing (LAV)No separation from reference connectorPass
    Resistance to Overriding (LAV)No overriding of threadsPass
    Visual Inspection (Rotating Hemostasis Valve)Met visual specificationsPass
    ID (Male Luer) (Rotating Hemostasis Valve)Met ID specificationPass
    ID (Compression Seal) (Rotating Hemostasis Valve)Met ID specificationPass
    ID (Side Port) (Rotating Hemostasis Valve)Met ID specificationPass
    Seal Integrity (Pressure) (Rotating Hemostasis Valve)No leakage or collapse under pressurePass
    Seal Integrity (Aspiration) (Rotating Hemostasis Valve)No leakage or collapse under aspirationPass
    Gauging (RHV Hub Luer)Met conical part of lock fittingPass
    Liquid Leakage (RHV Hub Luer)No leakage sufficient to form a falling dropPass
    Air Leakage (RHV Hub Luer)No continued formation of air bubblesPass
    Separation Force / Unscrewing Torque (RHV Hub Luer)Fitting remained attached to reference fittingPass
    Ease of Assembly (RHV Hub Luer)Met requirements for small bore connectorsPass
    Resistance to Overriding (RHV Hub Luer)No overriding of threads or lugsPass
    Stress Cracking (RHV Hub Luer)Withstood stress crackingPass

    2. Sample Size Used for the Test Set and Data Provenance

    • Bench Testing: The specific sample sizes for each bench test are not explicitly stated in the document. However, the results consistently state "All samples met the pre-determined acceptance criteria," implying that a sufficient number of samples were tested to gain confidence in the results according to the referenced standards. The data provenance is from internal testing conducted by Neuravi Ltd.
    • Animal Studies: The document mentions "Acute animal study has been performed." The specific number of animals is not provided. The model used was a swine model. This is prospective data from animal testing.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    This information is not applicable. The device is a medical catheter, and its performance is evaluated through physical and biological testing, not by expert interpretation of images or other data that would require "ground truth" to be established by experts in the context of an AI study.

    4. Adjudication Method for the Test Set

    This information is not applicable. The device is a medical catheter, and its performance is evaluated through physical and biological testing.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC comparative effectiveness study was conducted. This device is a physical medical device, not an AI algorithm requiring human reader performance evaluation.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    This information is not applicable. The device is a physical medical device, not an AI algorithm.

    7. Type of Ground Truth Used

    The "ground truth" for this device's performance is established through adherence to recognized international standards, internal specifications, and comparison to a predicate device. For example:

    • Biocompatibility: Based on established biological response criteria defined in ISO 10993 series standards (e.g., non-cytotoxic, non-sensitizing, non-pyrogenic).
    • Bench Testing: Based on pre-determined product performance specifications derived from relevant ISO standards (e.g., ISO 10555, ISO 11070) and FDA guidance documents.
    • Animal Studies: Based on evaluation of usability, effectiveness, safety (histological evaluation), and comparison to the predicate device in a swine model.

    There is no "expert consensus," "pathology," or "outcomes data" in the sense of a medical diagnostic ground truth for an AI algorithm.

    8. Sample Size for the Training Set

    This information is not applicable. The device is a physical medical device, not an AI algorithm.

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable. The device is a physical medical device, not an AI algorithm.


    Summary for this specific device:

    The K212340 submission for the EMBOGUARD™ Balloon Guide Catheter focuses on demonstrating substantial equivalence to an existing predicate device (8F FlowGate Balloon Guide Catheter, K153729) through extensive non-clinical testing.

    • Acceptance Criteria: For all tests, the acceptance criteria were pre-determined specifications, often derived from international standards (e.g., ISO 10993, ISO 10555, ISO 11070, ISO 80369) and FDA guidance documents. For comparison studies, the criterion was similarity or equivalence to the predicate device.
    • Device Performance: The device "Passed" all listed biocompatibility, sterilization/shelf-life, and bench tests, indicating it met the pre-determined acceptance criteria for each.
    • Study Types: The studies included:
      • Biocompatibility Testing: Covering cytotoxicity, sensitization, intracutaneous irritation, systemic toxicity, hemocompatibility (hemolysis, complement activation, thrombogenicity), and genotoxicity.
      • Sterilization and Shelf Life Studies: Validation of EtO sterilization and 1-year shelf life.
      • Bench Testing: A comprehensive suite of physical and mechanical tests covering visual inspection, dimensions, torque, tensile strength, flexibility, kink resistance, lubricity, coating, particulates, radiopacity, simulated use (including clot retrieval), user evaluation, compatibility with ancillary devices, lumen integrity, and balloon performance. All these were direct physical tests of the device.
      • Animal Studies: An acute animal study in a swine model to assess usability, effectiveness, safety, and histological response compared to the predicate device.
    • No clinical studies were performed.
    • The document does not detail any AI component, and thus questions related to AI-specific metrics (sample sizes for training/test sets, expert ground truth, MRMC studies) are not relevant to this submission. The "ground truth" here refers to the validated physical and biological properties of the device as measured against established scientific and regulatory standards.
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